Preparing for a FISMA Security Audit

The auditors are coming… The auditors are coming! Signal, one if by LAN. Two if by… oh, never mind. Let’s face it: Your annual IT security audits aren’t exactly the Revolutionary War, and the auditors aren’t really the "bad guys," but sometimes it feels that way. We all know the auditors are "here to help," but audits can quickly turn into an "us-against-them" battle, especially once they show you their list of findings. So now that you know they’re coming, what do you do? How do you prepare for the audit, and what do you do when they issue their findings? Randy Nash examines how to survive the audit gauntlet.

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Audits and auditors—no one really likes to see them coming, but
they're a fact of life. Believe it or not, they are the good guys.
That's difficult to remember when they announce their annual Federal
Information Security Management Act (FISMA) grades. The
FISMA reports
have become the de facto standard measurement for how government
agencies are performing in the security arena. Unfortunately, there's a lot
of misunderstanding about these grades. FISMA does not measure the
security posture or preparedness of any agency. Instead, it measures how well
the agency complies with federal regulations and public law, and how well it
manages its own security program.

Regulations and guidance have changed over the years. The laws have become
more specific, and the guidance has taken on greater and greater challenges,
providing ever more technical guidance on how to achieve security goals.
Unfortunately, the reporting methodology and the proper understanding of the
results and grades are not generally well understood. The actually criteria for
FISMA reporting is basically the same, but each year the Office of Management
and Budget (OMB) changes focus to another area of interest, and this "hot
topic" gets some additional weight in the overall scoring process.
Regardless of all this, it is still fairly easy to be well prepared for a FISMA
Audit

Prepare in Advance of an Audit

Audits tend to be performed on a schedule, so it should be easy to be
prepared in advance. Your auditors will certainly wish to see your most current
security documents (you do have a Security Plan, right?). What about
your security policy, rules of behavior, business continuity, disaster recovery,
incident response, change control, security test and evaluation, etc.? Do you
have standard build documentation for your servers? What about a high-level
design? Network diagrams? Have all of this ready for the initial
meeting with the auditors, before they take a look at your system:

Documentation should include proper labeling (such as "For Official Use
Only"), whether it's provided in hardcopy or electronic format. Do you
have policies on how this information should be handled? Will you allow the
auditors to keep the documentation after the audit is completed, or must it be
returned? Do you require a signature to release the information? Make sure you
follow all your own policies.

Do you have all your security controls implemented? Probably not, but
that's okay...as long as you have documented all your deficiencies. It may
not be possible to have all security controls in place, or to know about all
your vulnerabilities. If this is the case, you need to document what is not done. For example, if you plan to implement a new log management
tool but haven't gotten around to it, document the goal in a Plan of Action
and Milestones (POAM). This shows that you're not only aware of the
weakness, but you have a plan to address it. Too many times, the response is
"we know about it, but haven't gotten around to it yet." That
buys nothing with an auditor. Documenting the POAM shows that you know your
environment and you have documented proof.

Make sure all key people attend the initial meeting with the auditors.
Frequently there's no one person who knows everything about a given system.
Have everyone present who may be necessary (within reason) to answer key
questions by the auditors.

Cooperate During the Audit

Wherever possible, cooperate with the auditors. Provide whatever they need
and perform whatever tasks they request, as long as it doesn't violate any
existing policies. While an auditor won't generally try to trick you into
violating policies, he won't hesitate to call you on it if you do. If there
is a request that you feel violates some given policy, the request should be
brought to the appropriate person to determine how it should be handled. Most
people on staff only have the authority to say "No." Somewhere in the
chain of command is a person with the authority to say "Yes." Make
sure that person gets the request.